Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax for the calendar year 1939 in the amount of $1,568.18, and an overassessment for the year 1938. This proceeding, so far as it pertained to 1938, was dismissed for lack of jurisdiction. Thus, the taxable year in issue is 1939, and the only question is whether petitioner, as grantor, is taxable upon trust income under section 22 (a) of the Internal Revenue Code. One other...
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